What counts as a precious product under AUSTRAC rules?

Precious products include jewellery, watches, and items of personal adornment made of or containing precious metals or stones. Precious metals include gold, silver, platinum, palladium, iridium, osmium, rhodium, and ruthenium. Precious stones include diamonds, opals, pearls, sapphires, and garnets.

Is bullion regulated differently to jewellery under AUSTRAC?

Yes. Bullion — gold, silver, platinum, or palladium in bar, ingot, or wafer form — is a separate designated service regulated at any transaction value and through any payment method, not just cash over $10,000. If you sell bullion, you are a reporting entity regardless of how your customers pay.

What if I only accept card payments — am I still regulated by AUSTRAC?

If you have a clear, documented business policy never to accept cash or virtual asset payments of $10,000 or more and strictly enforce it, you may not be regulated for precious metals transactions. AUSTRAC recommends documenting this policy explicitly in writing, including staff instructions. Bullion dealers remain regulated regardless of payment method. This exemption is narrow and subject to strict conditions — do not assume cash transactions are permitted without verifying eligibility. Seek legal advice if unsure.

Do pawnbrokers need to comply with AUSTRAC Tranche 2?

Yes. Pawnbroking is a designated service under the AML/CTF Act 2006. If your business accepts goods — including jewellery, watches, or precious metals — as security for loans, you must enrol with AUSTRAC, implement an AML/CTF Program, conduct customer due diligence, and meet all reporting obligations, which are now in effect since 1 July 2026.

What is a Threshold Transaction Report and when must jewellers submit one?

A Threshold Transaction Report (TTR) must be submitted to AUSTRAC for any cash transaction of $10,000 or more, including physical currency and virtual assets. For jewellers, this means any single sale or purchase where the customer pays $10,000 or more in cash. The report must be submitted via AUSTRAC Online within 10 business days of the transaction.

What is structuring and why is it a criminal offence for jewellers?

Structuring is when a customer deliberately splits a transaction into amounts below $10,000 to avoid triggering a Threshold Transaction Report. Under the AML/CTF Act 2006, structuring is a criminal offence. Jewellers must be alert to customers making multiple smaller purchases within a short period that together would exceed $10,000.

How do I submit a Suspicious Matter Report to AUSTRAC?

Log into AUSTRAC Online at online.austrac.gov.au, select Reporting, then Submit SMR. Complete all mandatory fields including a detailed narrative of the suspicious circumstances. Terrorism financing suspicions must be reported within 24 hours. All other SMRs must be submitted within 3 business days.

What records must jewellers keep and for how long?

Different AML/CTF record categories have different retention rules and statutory triggers. Program records, CDD records, transaction records, reporting records and training or program-compliance records must be retained for their applicable statutory periods. Records must be stored securely and be retrievable for AUSTRAC examination or court proceedings.

Does the $10,000 cash rule apply per item or per transaction?

The $10,000 threshold applies per transaction, including linked transactions. A single sale of multiple items totalling $10,000 or more in cash triggers the TTR reporting obligation. AUSTRAC also requires vigilance for linked transactions — multiple purchases structured to stay below the threshold individually may still trigger reporting and SMR obligations.

What if my customer pays partly cash, partly card?

If the total transaction value is $10,000 or more and any portion is paid in cash, a Threshold Transaction Report is required for the cash component. You must report the full cash amount paid, even if only part of the purchase price was settled in physical currency. The card component does not reduce the cash reporting obligation.

Do jewellers need to verify identity for every sale?

Customer due diligence is required before providing a designated service. For jewellers, this means verifying identity for cash transactions of $10,000 or more, and applying enhanced due diligence for high-risk customers or transactions. Standard retail sales well below the threshold do not individually trigger CDD obligations, but your AML/CTF Program must specify your thresholds and procedures.

Can a jeweller refuse a sale if a customer won't show ID?

Yes. Under your AML/CTF Program, you must not provide a designated service if you cannot complete the required customer due diligence. If a customer refuses to provide identity documents for a transaction that triggers your CDD obligations, you must decline the transaction and may be required to file a Suspicious Matter Report.

What is a PEP and why does it matter for a jewellery business?

A Politically Exposed Person (PEP) is an individual who holds or has held a prominent public position — such as a government minister, senior official, or their close associate. Transactions with PEPs carry higher money laundering risk and require enhanced CDD under your AML/CTF Program, including verifying the source of funds for high-value jewellery or precious metal purchases.

Do I need a separate compliance officer or can it be the owner?

The owner or a senior employee can be designated as the AML/CTF Compliance Officer — there is no requirement for a dedicated full-time role. The Compliance Officer must be clearly named in your AML/CTF Program, responsible for staff training, AUSTRAC reporting, and reviews required under the applicable statutory framework.

What is beneficial ownership and why does it matter for jewellers?

Beneficial ownership refers to the natural person who ultimately owns or controls a company or trust making a purchase. Jewellers must identify and verify the beneficial owner of any corporate customer that conducts high-value or suspicious transactions. Obscuring beneficial ownership is a known money laundering technique and a red flag under AUSTRAC guidance.

Do jewellers need to verify the identity of wholesale suppliers?

Your CDD obligations primarily apply to customers — parties to whom you provide a designated service. For wholesale suppliers, you should apply appropriate due diligence proportionate to your risk assessment, particularly if dealing in large volumes of precious metals or stones. Your AML/CTF Program should specify your supply chain risk procedures.

What happens if my business misses the 29 July 2026 enrolment deadline?

Operating as a reporting entity without enrolling with AUSTRAC is a contravention of the AML/CTF Act 2006 and may attract civil or criminal penalties. AUSTRAC has indicated it will take a risk-based approach to enforcement. The 29 July 2026 transitional enrolment deadline has passed, and businesses that remain unenrolled face significant legal exposure. Enrolment opened at online.austrac.gov.au on 31 March 2026.

Does Klyvon's output satisfy AUSTRAC's AML/CTF program requirements?

Klyvon generates compliance documents built on AUSTRAC's official guidance and citing the AML/CTF Act 2006 and AML/CTF Rules 2025 throughout. The documents are personalised to your business and structured to meet the risk management framework and CDD procedure requirements under the Act. They are a strong starting point — we recommend review by a qualified AML/CTF adviser before operational reliance.

Does Klyvon include sanctions screening?

Targeted financial sanctions screening is now part of your AML/CTF program obligation under the AML/CTF Rules 2025 — not a separate exercise. Klyvon's generated program includes the required policy controls for targeted financial sanctions. You will still need to screen clients against the DFAT Consolidated List as part of your CDD workflow. Klyvon does not run live screening checks, but your program documents exactly when and how to do it.

How often must jewellers get an independent evaluation of their AML/CTF program?

At least once every 3 years, and more often if appropriate to the size and complexity of your business. The independent evaluation must assess: your ML/TF risk assessment against the Act and Rules, the design of your AML/CTF policies, your actual compliance with those policies, and whether you're appropriately identifying, assessing, and mitigating ML/TF risk. Findings go in a written report to your governing body or a responsible senior manager.

I started providing a designated service after 1 July 2026 — do I still need to enrol by 29 July 2026?

No. The 29 July 2026 date only ever applied to businesses that were already providing a designated service on 1 July 2026, and that date has passed. If you started after 1 July, you have 28 days from the date you started to enrol with AUSTRAC — this rule applies on an ongoing basis, not just around the Tranche 2 rollout. Full explanation and worked examples: https://www.klyvon.com.au/austrac-enrolment-28-day-rule.

Updated August 2026

Field Guide · Jewellers & Precious Metals Dealers

AUSTRAC AML/CTF requirements for jewellers

AUSTRAC's own worked example: three cash purchases, same customer, three weeks, each sized just under $10,000. No individual sale crosses the threshold — the pattern still requires an SMR.

Generate my compliance documents →See the structuring example

$10,000
Cash TTR threshold: 29 Jul
Enrolment deadline (passed): 3 days
SMR lodgement: 10
Published red flags

Jewellers and precious-product businesses may be regulated by AUSTRAC when they provide a designated service involving precious metals, precious stones or precious products. This page explains the $10,000 cash or virtual-asset threshold for relevant jewellery transactions and the separate rules for bullion dealers. AML/CTF obligations have been in effect since 1 July 2026.

⚠ Enrolment deadline passed 29 July 2026 · Dealers not yet enrolled are exposed to enforcement nowaustrac.gov.au ↗

In this guide

AUSTRAC's structuring example Does my business need to comply?All 10 red flags AUSTRAC watches for What Klyvon generates for you What AUSTRAC requires, step by step Frequently asked questions Get compliant with Klyvon

I. The Pattern, Not the Purchase

Is a customer paying just under $10,000 a red flag?

On its own, no. Three times in three weeks from the same customer — that's the exact pattern AUSTRAC published as a warning.

USTRAC has published a worked example of precisely this pattern: three cash purchases by the same customer over three weeks, each sized just below the reporting threshold, totalling nearly $25,000. No individual purchase ever triggers a Threshold Transaction Report. That’s the point — structuring exists specifically to stay under the wire one transaction at a time. AUSTRAC treats the pattern as a strong indicator warranting a Suspicious Matter Report regardless of whether any single sale crossed $10,000.

AUSTRAC’s published worked example — no single transaction crosses $10,000

Week 1

Just under $10,000

Week 2

Just under $10,000

Week 3

Just under $10,000

Same customer, 3 weeks

Combined total: nearly $25,000

No TTR triggered
individually — SMR
still required

Structuring is a criminal offence under the AML/CTF Act 2006 — the pattern, not any single purchase, is what triggers the reporting obligation.

“Structuring is a criminal offence — a jeweller who facilitates it, knowingly or through inadequate procedures, may also face liability.”
— AML/CTF Act 2006

II. Who's In Scope

Does my jewellery business need to comply with AUSTRAC?

Cash or virtual assets at $10,000 or more pulls you in — with one narrow exception, and one category that has no threshold at all.

Jewellery & precious stones

Regulated at $10,000+ cash or virtual asset — with a narrow documented-policy exemption available.

Bullion

Regulated at any transaction value, any payment method — no exemption available.

Your business is a reporting entity if it sells or purchases precious metals, precious stones, or precious products and accepts cash or virtual asset payments of $10,000 or more in a single transaction or linked transactions. Businesses with a clear, documented policy prohibiting cash or virtual asset payments of $10,000 or more — and that strictly enforce it — may not be regulated for precious metals transactions. Bullion is different: it’s regulated at any transaction value, through any payment method, with no exemption available.

III. What AUSTRAC Watches For

Ten patterns published for jewellers and precious metals dealers

None of these alone proves anything — a customer can tick one box for an entirely ordinary reason. What matters is whether, taken together, a reasonable person in your position would start to wonder.

Sales conducted entirely online or by phone

Face-to-face contact helps identify hesitation, inconsistent stories, and behavioural cues much harder to pick up remotely — a real risk factor AUSTRAC's guidance names specifically.

Can't or won't explain source of funds

For high-value purchases, especially cash, a customer who can't or won't explain where the money came from warrants enhanced due diligence and possible SMR lodgement.

Anonymous buyer or unexplained intermediary

A customer purchasing without identifying information, or acting through a third party with no clear relationship, is a significant red flag — CDD cannot be completed without it.

Requests to split invoices or payments

A customer explicitly asking for a single purchase to be split across multiple invoices or payment methods to reduce the apparent value is a structuring indicator.

Purchases inconsistent with financial capacity

High-value jewellery bought in circumstances inconsistent with apparent financial means requires enhanced scrutiny — AUSTRAC's national risk assessment flags retail jewellery specifically for this.

Items pawned or sold back shortly after purchase

Since pawnbroking is itself a designated service, buying high-value jewellery and pawning or reselling it soon after — particularly at a loss — is a pattern worth escalating.

Rapid buying and reselling

Quick resale of the same items, particularly at a loss or with no commercial rationale, may be placing or layering criminal proceeds.

Virtual asset payments for high-value items

Cryptocurrency payments for jewellery or precious stones, particularly in high volumes or from unknown parties, warrant enhanced CDD and source-of-funds verification.

Unusually concerned about avoiding ID checks

A customer asking to skip verification, offering a premium to avoid it, or becoming evasive under standard CDD questions must be treated as high-risk.

Beneficial ownership obscured behind a company

A corporate customer where the true controller isn't disclosed is a known laundering technique — verify beneficial owners for any high-value or suspicious corporate purchase.

IV. What You Get

Five documents, built for your specific business

Not a generic template — your name, your compliance officer, your services, generated for review.

AML/CTF Program Document

Firm-specific compliance program citing the AML/CTF Act 2006 throughout. Covers cash threshold rules, TTR obligations, structuring detection, and jeweller-specific risk factors.

Client Due Diligence Forms

CDD procedures for individual and company clients with precious-metals-specific enhanced CDD triggers, including source of funds requirements for high-value transactions.

Role-Based Staff Training + Certificate

Mandatory now that obligations are in effect — interactive modules tailored to each staff member's role, with jewellery-sector scenarios covering structuring and red flags. Dated certificate per person, retained for the applicable statutory period.

Compliance Officer Letter

A record of the business's compliance-officer designation. The business remains responsible for ensuring the designated individual meets the applicable requirements.

SMR Assistant

When suspicion arises, you have 3 business days to file. Klyvon prepares an SMR draft from the information entered for review before submission through AUSTRAC Online.

V. What AUSTRAC Requires

Eight steps every in-scope dealer must have completed

Klyvon generates the documents this list requires automatically — enrolment and training are the two steps that stay yours to action.

Enrol with AUSTRAC now if not enrolled

Appoint an AML/CTF Compliance Officer in writing

Designate a named individual — owner or senior employee — responsible for your compliance program, AUSTRAC reporting, and staff training.

Complete a written ML/TF Risk Assessment

Assess your exposure across client types, transaction values, payment methods, and geographic risk — and document it in your Program.

Implement a written AML/CTF Program

Your Program must cover CDD procedures, transaction monitoring, TTR obligations, SMR procedures, and your record-keeping policy.

Train relevant personnel on AML/CTF obligations and red flags

Provide initial and ongoing AML/CTF training for personnel performing relevant functions, appropriate to their functions, relevant ML/TF risks and responsibilities.

Submit Threshold Transaction Reports for cash sales of $10,000+

10 business days

Any single cash transaction of $10,000 or more must be reported to AUSTRAC via AUSTRAC Online within 10 business days.

Submit Suspicious Matter Reports when suspicion arises

3 days / 24 hrs

If you suspect a customer is engaged in money laundering, terrorist financing, or structuring, submit an SMR within 3 business days — or 24 hours for terrorism financing.

Schedule your independent evaluation

At least once every 3 years (more often if your business's size or complexity warrants it), arrange an independent evaluation covering your risk assessment, policy design, actual compliance, and risk mitigation effectiveness.

Penalties and professional consequences

Civil penalties for body corporates can reach up to $36,400,000 per contravention (based on the $364 penalty unit rate effective 1 July 2026). AUSTRAC publishes enforcement actions publicly — a penalty carries reputational consequences beyond the financial impact, and professional licences and industry association memberships, including with the Jewellers Association of Australia, may also be affected. Penalty figures are indicative — refer to current legislation for precise amounts.

VI. Reference

Common questions from jewellers

VII. How Klyvon Helps

Compliance doesn’t end at enrolment — Klyvon runs alongside your business

Your program, risk assessment, and CDD templates are generated for review. Then Klyvon keeps working — tracking staff training and review dates, drafting SMRs, and answering the questions that come up between reviews.

Risk assessment, built to your business

A documented ML/TF risk assessment across your client types, transaction values, and payment methods — not a generic template with your business's name on it.

Mandatory training, by role — not a generic quiz

Interactive modules assigned by staff role, with jewellery-sector scenarios. Completion certificates generated automatically and retained for the applicable statutory period — required now that obligations are in effect, not optional.

SMR drafting when suspicion arises

Prepare an SMR draft from the information entered for review before submission through AUSTRAC Online.

Answers instead of pointing you at a PDF

Ask a plain question about a real sale — a customer who's paid just under $10,000 twice this month, an unexplained third party collecting an order.

Get started free →

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Primary sources

AUSTRAC — Tranche 2 reform guidance

Last updated 20 August 2026 · Klyvon Compliance Team

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